Retail Leadership Excellence Programme

Store Manager Privacy Notice

 

- Introduction
- Who we are and how to contact us
- When this Notice applies to you
- How we collect your personal data
- The types of personal data and information we collect
- Why we collect your personal data and how we use it
- How we use your personal data
- How long we keep your personal data
- Confidentiality and security of your personal data
- How to access your personal data and your other rights
- Changes to this Notice

 
Introduction

Value Retail is committed to protecting your personal data. It’s your data, and we respect that. This Privacy Notice (the “Notice”) provides detailed information on when and why we collect your personal data, how we use it, who we share it with, how we keep it secure and comply with applicable data protection law. This Notice also describes your right to request that we delete, update, transfer or provide you with access to your personal data.

This Notice relates to our Value Retail Retail Leadership Excellence Programme (the “Programme”). The Programme consists of regular assessments of your performance using our Store Manager Competency Framework, which will enable us to suggest and deliver complementary training and development requirements so that you are appropriately qualified, skilled and experienced to continue to achieve high standards of performance as an employee of one of our Village Brand Partners.

Other privacy notices may also apply to your personal data – for example the Privacy Notice which applies to the Village you work in and the privacy notice or statement provided to you by your employer (our Village Brand Partner).

 

Who we are and how to contact us

This Notice explains how Value Retail Management Limited  (and its affiliated companies) collect, use, share and manage your personal data in the Programme. Value Retail Management Limited  owns and administers the Programme together with its affiliated companies and we will each be a controller of your personal data as “Joint Controllers”. Depending on the Value Retail Village in which you work as a Village Brand Partner employee, one of our affiliated companies will be asked to conduct or assist in assessment and training activities as a Joint Controller.

You may contact Value Retail Management Limited  with any questions relating to this Notice or the Programme, or to exercise your rights described in this Notice by emailing RetailExcellence@ValueRetail.com.

As Joint Controllers, we have arrangements between us to ensure that we handle your personal data properly and in accordance with data protection law. These arrangements reflect our respective roles and responsibilities in relation to you and your personal data. These arrangements between us do not affect your rights under data protection law. For more information on these arrangements please contact us using the email address above.

Your employer (our Village Brand Partner) will process personal data about you in relation to your employment relationship with them and will always be the data controller of that data. All interaction and exchange of personal data between our Brand Village Partner and Value Retail is managed by contractual arrangements between us as independent data controllers.

 

If you are located in Germany:

Value Retail has appointed Dr. Felix Wittern as Data Protection Officer for Germany. Dr. Wittern can be contacted at Fieldfisher (Germany) LLP, Am Sandtorkai 68, 20457 Hamburg, Germany or via email at datenschutzbeauftrager@valueretail.com.

 

When this Notice applies to you

This Notice will apply to you when, during the course of your employment with one of our Village Brand Partners, assessments are conducted about your competencies using our Store Manager Competency Framework and when you attend Value Retail-runtraining events.

Not all individuals who will be assessed in the Programme will hold the job title ‘Store Manager’. This is because we will perform assessments against those Village Brand employees who are formally appointed by the Brands and whose responsibilities include:

  • responsible for the day to day operations and management of the store or more than one store;
  • responsible for all store employment matters including recruitment, performance management, training and development and shift scheduling. In large stores this may include assistant managers and supervisors as well as store managers and category managers;
  • responsibility for the appearance/presentation of the store and advertising displays;
  • accountable for product management including ordering and receiving price changes, handling damaged product and returns;
  • responsible for the management of guest experience, including complaints and feedback;
  • responsible for target setting and analysis of all key performance indicators; and
  • responsible for setting budgets and building plans to achieve those budgets.

How we collect your personal data

We collect personal data about you from your employer, when assessments are conducted and when you attend training events. This personal data is collected or created by our personnel.

The types of personal data we collect

We only collect the personal data and information that is necessary to perform assessments and to deliver tailored training suggestions.

Here is the personal data we collect when we manage the assessment process:

  • Name and Surname

o Business email address

o  Business mobile phone number

  • The name of the Value Retail Village you work in
  • Name of your employer (our Village Brand Partner)
  • Position (job title name)
  • Length of time you have been in your role
  • Any significant role changes in the last year
  • Date of your last assessment
  • Measurement of your Leadership, Mindset, Skills, Attitude and Knowledge (which form part of the Store Manager Competency Framework) as they apply to your role

 

Here is the personal data we may collect when you attend our training events:

  • Name and Surname

o  Business email address

o  Business mobile phone number

  • The name of the Value Retail Village you work in
  • Name of your employer (our Village Brand Partner)
  • Position (job title name)
  • Details of the training event (date, time, name of training event)
  • Records of attendance
  • Performance
  • Any test or assessment results

 

Why we collect your personal data and how we use it

We have a legitimate interest in collecting and processing the personal data described in this Notice so that we can:

  • maintain high standards of performance by Store Managers by highlighting and developing strengths and identifying and supporting areas for improvement
  • ensure that any underperforming Store Managers are provided with appropriate assistance, complementary training and attention to help them improve their performance
  • apply a fair, calibrated and consistent assessment process for all Store Managers who work for our Village Brand Partners
  • create assessment summaries and output and share them with your employer and with other Value Retail personnel
  • collate and assess Store Manager performance throughout a Brand Partner, Village or at Value Retail group level to understand if the Programme objectives and aims are being realized, to identify trends and potential improvements and to inform stakeholders and senior management.

 

Our use of your personal data must comply with applicable data protection law and establish at least one specific lawful reason for the processing. Examples of these lawful reasons include our legitimate business interests, prevention and detection of crime, or compliance with contractual obligations or applicable employment related law.

We will process personal data of our Village Brand Partner Store Managers for the purposes of our legitimate business interests. We have conducted an assessment to ensure that your rights and freedoms do not outweigh our interests in processing your personal data as described in this Notice. This assessment has been used to implement the way we process your data to ensure your rights are adequately protected. For further information about that assessment, including to exercise your right to challenge our decision, please contact us using the details in the ‘Who we are and how to contact us’ section of this Notice.

Additionally, sometimes we also need to process your personal information to comply with our legal obligations including in relation to handling complaints and investigations or litigation.

 

How we use your personal data

We use your personal data to provide a sophisticated performance assessment process that is specifically tailored to our Villages and the level of hospitality and performance we and our Village Brand Partners expect. The assessment process is carried out in several stages, all of which have been thoroughly reviewed to ensure that your rights and freedoms regarding your personal data are sufficiently protected. The below gives you an overview of this process.

  1. Bi-annually, the Village Retail Managers will complete and submit an assessment for the Store Manager of each Brand Partner they are responsible for managing. The assessments consist of questions in the categories of leadership, mindset, skills, knowledge and attitude, as well as a free form text field for additional commentary in each category.
  2. The Brand People Training Manager will hold a meeting with representatives from the Village Visual Merchandising, Retail Management, Senior Management and Hospitality Management Teams. This combined set of managers will discuss and confirm or change the scores provided by the Village Retail Managers in step 1. The process (called the ‘Calibration Process’) is designed to ensure that fair and consistent scores are achieved in each assessment cycle and that all Value Retail Managers with whom Store Managers have regular contact have an opportunity to contribute.
  3. At the end of the Calibration process, the software will produce a graph which shows the total score in each category, including an indication of which core competency training topics are most relevant. This enables the Brand People Training Manager to review and recommend appropriate, tailored training elements to compliment the Store Manager’s strengths and help to address areas for improvement. An ‘Output Report’ will be produced which details all of this data.
  4. Depending on the wishes of your employer, we will either provide the Output Report directly to them or will set up a meeting with you to discuss the recommended training elements. The recommended training is not compulsory and your attendance is at the discretion of your employer and your personal choice.
  5. We will create two different types of cluster maps, one for the Village and one for our Brand Partner (if the Brand Partner is present in more than one village). These maps will provide a picture of the performance of individual Store Managers compared to the respective group. Placement in the graph may also trigger more frequent assessments. The increased frequency will help Value Retail to determine if the recommended trainings and coaching are having the desired impact and also to identify where additional support for Store Managers may be required if little or no improvement is evident.

Sharing your personal data

We will share output data from the assessments we conduct, together with any recommended training with your employer and other companies within its group (if Value Retail has a relationship with these group companies). Your employer will also be a data controller of the personal data we share, which will be managed in accordance with their data protection policies and procedures.  

We will share your personal data with other Value Retail entities which need to access it for administrative purposes such as managing training events and facilitating reporting.

We may also share your personal data with consultants and professional advisors who assist us from time to time. Please contact us if you would like to know more about this.

In limited circumstances, we may disclose your personal data:

  • To suppliers that process information and/or personal data on our behalf in connection with our use of technology platforms;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation (such as providing it to government authorities or regulators);
  • In order to protect the rights, property or safety of our business, our guests or others.

We check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal data, with particular regard to technical and organisational measures. We have written contracts with them which provide assurances regarding the protections that they give to your personal data and their compliance with our data security standards and any relevant international transfer requirements.

All information collected, created, disseminated and stored for the purposes of this programme is housed in applications which are provided to us under contract by Microsoft Inc. and is stored in datacentres in the EU. Click here for a description of these services.

How long we keep your personal data

We apply careful analysis to make sure we only hold your personal data for as long as it is needed.

  • We will retain personal data about the assessments we conduct for the duration of your employment with your employer at one of our Villages. When you leave our Village we will delete all of your personal data within 6 months.
  • We will retain personal data about recommended training, completed training and training outcomes for the duration of your employment with your employer at one of our Villages. When you leave our Village we will delete all of your personal data within 6 months.
  • We will retain personal data in our email systems in line with our retention polices and schedules.
  • We will retain personal data in cluster maps for 2 years.

Confidentiality and security of your personal data

We are committed to keeping your personal data secure throughout its lifecycle and we will take appropriate precautions to protect it from loss, misuse or alteration.

We have implemented information security policies, rules and technical and organisational measures to protect your personal data from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All of our employees and the third party partners with whom we share your personal data are obliged to respect the confidentiality of the personal data of all individuals.   

 

How to access your personal data and your other rights

You have the following rights in relation to the personal data we are processing about you which can be exercised by emailing RetailExcellence@ValueRetail.com.    

You should note that if your request relates to data which is being processed by your employer we will not have access to or oversight of that data. Your employer is the data controller of that personal data and we will not be able to respond to your request.

  1. Right to be informed of the personal data we are processing about you.

You have the right to be provided with clear, transparent and easily understandable information about how we collect and use your personal data. This is why we’re providing you with the information in this Notice.

  1. Right of access to the personal data we are processing about you.

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

  1. Right to correct the personal data we are processing about you.

If the personal data we hold about you is inaccurate or incomplete, you’re entitled to have it corrected. If we’ve shared your personal data with others, we’ll let them know about the changes where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

  1. Right to delete the personal data we are processing about you.

This is also known as ‘the right to be forgotten’. You can ask us to delete or remove your personal data in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal data with others, we’ll let them know about the deletion request where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

  1. Right to restrict our processing of your personal data.

If you ask us to stop processing your personal data we may not be able to provide you with all the benefits of the Programme.

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it. We will still be able to store your personal data. We’ll tell you before we lift any restriction. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

  1. Right to object to our processing of your personal data.

If you ask us to stop processing your personal data we may not be able to provide you with all the benefits of the Programme.

You can ask us to stop processing your personal data, and we will do so, if we are relying on our legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; our interests must override your interests, rights and freedoms or be for the establishment, exercise or defence of legal claims.

  1. Rights in relation to automated decision making and profiling using your personal data.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you.

  1. Right to complain to a data protection supervisory authority.

If you have a concern about any aspect of our data protection practices, including the way we are processing your personal data, you can report it to the your local data protection Supervisory Authority. Their contact details are contained in the table below.

Country

Supervisory Authority

Website

United Kingdom

The Information Commissioners’ Office (ICO)

https://ico.org.uk/

Ireland

The Data Protection Commission (DPC)

https://www.dataprotection.ie/docs/Home/4.htm

France

Commission Nationale de l’Informatique et des Libertés

(CNIL)

https://www.cnil.fr/fr

 

Italy

Garante per la protezione dei dati personali (Garante)

https://www.garanteprivacy.it/web/guest/home 

Spain

Agencia Española de Protección de Datos (AEPD)

https://www.agpd.es/

Belgium

Gegevensbeschermingsautoriteit (GBA)

 

Autorité de protection des données (APD)

https://www.gegevensbeschermingsautoriteit.be/

https://www.autoriteprotectiondonnees.be/

Germany

Data protection for private sector organisations is overseen by regional data protection authorities. Value Retail operates in two regions within Germany and,

therefore, falls under the jurisdiction of two supervisory authorities.

Bavaria

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)

https://www.lda.bayern.de/de/index.html

Baden-Württemberg

Der Landesbeauftragte für den Datenschutz Baden-Württemberg

https://www.baden-wuerttemberg.datenschutz.de/

 

 

Changes to this Notice

We may make changes to this Notice from time to time. This Notice was updated on 09/04/2019.

To ensure that you are always aware of how we use your personal data we will update this Notice from time to time to reflect any changes to our use of your personal data. We may also update this Notice to comply with changes in applicable law or regulatory requirements. If we make substantial changes to the way we process your personal data we will let you know if this is possible and practical.

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